The reformed NHS contract in England has been running for five months. On 30 September your commissioner takes a reading, and for the first time unscheduled care is measured on its own line rather than folded into your UDA total. There is a specific percentage that triggers contract management action, and most practices have not worked out what their own number is.
Article · 1 September 2026
For twenty years the NHS dental contract in England has been monitored against a single number: UDAs delivered against UDAs contracted. Commissioners took a reading at the halfway point, wrote to anyone a long way behind, and settled up after 30 June the following year. Practices learned to manage to that one figure, and practice accountants learned to provide for the clawback that came out of it.
That is no longer the whole picture. NHS England describes the changes that took effect on 1 April 2026 as the first significant change to the contract since it was introduced in 2006, and the change that matters most for the mid-year review is structural rather than financial: unscheduled care is now reconciled separately from routine activity, at mid-year and again at year end. You can be comfortably on track for UDAs and still be in contract management difficulty on urgent care, and the first time many practices will discover that is when the letter arrives in October.
Four changes carry into the mid-year position.
The mid-year point covers activity from 1 April to 30 September. Two separate tests apply to it, and they are not weighted the same way.
On the UDA side, the reading is the familiar one: roughly half your contracted activity should be through by the halfway mark, and a large shortfall invites a conversation and a recovery plan.
On the urgent care side, the guidance is specific. Where delivery of the Required Number of Urgent Treatments is less than 30% of the required number during the period 1 April to 30 September, the commissioner is directed to act in accordance with regulation 59 of the GDS contract regulations. Note what that threshold is not: it is not 50%. The tolerance recognises that urgent care builds through the winter. But it is a hard line, and it is measured on a number most practices have never had to count before.
Take a practice with a negotiated annual contract value of £400,000. The figures below are illustrative, but the arithmetic is the arithmetic every English practice is now subject to.
Now the money. The £15 fixed credit attaches to the required number, so 440 × £15 = £6,600 arrives across the year regardless of volume. The £60 activity credit is earned course by course. Deliver all 440 and the practice receives £6,600 + £26,400 = £33,000. Deliver 380 — a shortfall most principals would not notice month to month — and the activity element falls to £22,800. That is £3,600 of activity payment associated with undelivered required treatments, and at year end the guidance recovers it.
Missing the 30% urgent care floor sends the contract into regulation 59 territory, which is the remedial route rather than an automatic penalty. In practice it means a conversation, an action plan and a documented recovery trajectory for the second half of the year.
The guidance also closes a door that principals might reasonably expect to be open. Commissioners do have discretion to reduce the Required Number of Urgent Treatments by up to 15% per contract, and that discretion is exercised in the window from 30 October to 31 March. But the guidance is explicit that failing to deliver 30% at mid-year does not, on its own, amount to adequate grounds for using it. Under-delivery is not a route to a smaller target. If there is a genuine reason your practice cannot meet the required number — a lost associate, a surgery out of action, a demographic that simply does not present urgently in your numbers — that case has to be made on its own merits, with evidence, and made early.
The reconciliation after the year closes runs in a specific order. Urgent care is settled first, on its own, and then the contract as a whole is assessed.
The other end of the range is worth knowing before you build a plan around catching up. Delivery above your negotiated annual contract value is not paid for unless it is agreed in advance with the commissioner, and even then the ceiling is 110%. Over-delivering your way out of a problem is a conversation to have in October, not a decision to take quietly in February and invoice for in April.
This is where the mid-year reading stops being an NHS England process and becomes an accounting one. Three consequences follow.
Clawback is a provision, not a surprise. If your mid-year position points at under-delivery, the expected recovery belongs in the accounts for the year it relates to, not the year the money is taken back. A practice with a 31 March year end that finds out in the following autumn what it owes has already signed off accounts that were wrong. Six months of Compass data in hand is enough to make a defensible estimate, and it is the difference between a clean set of accounts and a prior-year adjustment.
Associate cost does not fall in step with the shortfall. Where associates are paid per UDA delivered, an activity shortfall reduces their pay in proportion. Urgent care under the new structure does not behave that way — the £15 fixed credit is earned against the required number rather than the delivered one, and associate agreements written for the old 1.2-UDA world do not describe how the new payment is shared. If your agreements have not been revisited since April, the mid-year review is the moment they get read properly. Our note on associate pay models covers where those conversations usually land.
It changes what your practice is worth. Buyers price NHS income on its reliability. A contract carrying an unresolved urgent care shortfall and a live breach notice is a different asset from one delivering at 100%, and it will be found in due diligence. The clawback trap in practice purchases explains how the liability travels with a deal, and the valuation guide sets out how contract performance feeds the multiple. If a sale is anywhere in your two-year plan, the mid-year number is a valuation number.
The mid-year review has never been the event principals worry about, because in most years it was a letter about a number everyone already knew. This year it measures something new, against a threshold most practices have not calculated, in the first year of a contract nobody has managed before. If you would like us to work out your required number and your position against it, get in touch — it takes an hour and it is a great deal cheaper than finding out in June.
Deadlines coming up, rule changes that affect dentists, and one number worth checking — once a month, no spam.
Two things, separately. The first is the familiar one: UDAs delivered against UDAs contracted for the period from 1 April to 30 September. The second is new for 2026/27 — delivery of your Required Number of Urgent Treatments over the same six months, reconciled on its own line rather than folded into the UDA total. The specific trigger in NHS England's contractual guidance is delivery of less than 30% of the required number of urgent treatments in that period, which directs the commissioner to act under regulation 59 of the GDS contract regulations. Being on track for UDAs gives you no protection on the urgent care test, and vice versa.
Take your negotiated annual contract value and apply 8.2%, which is the proportion of contract value that must be delivered as unscheduled care in 2026/27 by any provider holding a mandatory services contract of 100 or more UDAs. NHS England restates the same requirement as 11 urgent courses of treatment for every £10,000 of contract value, which is the quicker way to get to a number. A £400,000 contract therefore needs 440 urgent courses across the year, and at least 132 of them — 30% — delivered by 30 September. Divide the annual figure by twelve to get the monthly run rate you should be managing to.
Not on that basis alone. Commissioners do hold discretion to reduce the Required Number of Urgent Treatments by up to 15% per contract, and that discretion is exercised in the window from 30 October to 31 March. But the guidance states plainly that failure to deliver 30% of the required number at mid-year does not by itself constitute adequate grounds for using it. A reduction has to be justified on its own facts — a surgery out of commission, a lost associate, a patient population that genuinely does not present urgently at that volume — with evidence, and put forward early rather than as a year-end rescue.
Undelivered UDAs above the 96% threshold are carried over into the next financial year, and the carried-over units are not restricted to urgent care — they can be used for any mandatory services. That is the meaningful relief in the reconciliation rules and it is why 96% is the number to manage to rather than 100%. Below 96%, the under-delivered activity payment is recovered through the standard process and a breach notice may follow. Urgent care is settled first and separately: where required urgent treatments fall below 96%, the activity payment associated with the undelivered courses is recovered even if overall contract delivery is fine.
Only within limits, and only by agreement. NHS England's guidance is that delivery above your negotiated annual contract value will not be paid for unless an agreement is made in advance with the commissioner to fund additional activity, and the ceiling on that is 110%. So over-delivery is neither automatic nor open-ended: doing more work in February and assuming it will be paid for in April is how practices end up funding NHS activity out of their own margin. If catching up is your plan, the agreement needs to be in place before the work is done, which realistically means raising it in October or November.
As a provision in the year the activity relates to, not the year the money is taken back. Once you have six months of Compass data you can estimate the year-end position well enough to support a figure, and that estimate belongs in the accounts for the year ending 31 March. Practices that wait until the reconciliation lands the following summer end up signing off accounts that overstate income and then correcting them by prior-year adjustment, which affects reported profit, the tax paid on it, and anything a lender or buyer takes from those figures. Keep the workings behind the provision — they are the first thing a purchaser's due diligence will ask to see.
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